Legal Opinion

Bridgeport Hydraulic Co. v. Commissioner

United States Tax Court

Decided April 30, 1954No. Docket No. 43322Published

1. Income Deduction -- Retirement of Bonds -- Expense or Cost of New Issue. -- The unamortized cost of issuance and the cost of retirement are deductible when bonds are unconditionally called and the debt is paid in cash even though in a separate transaction a new issue is sold at about the same time to the holders of the old bonds. 2. Amortization -- Retirement of Bonds Through Exchange of New Issue. -- The unamortized cost of issuance and the cost of retirement of old…

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1. Income Deduction -- Retirement of Bonds -- Expense or Cost of New Issue. -- The unamortized cost of issuance and the cost of retirement are deductible when bonds are unconditionally called and the debt is paid in cash even though in a separate transaction a new issue is sold at about the same time to the holders of the old bonds. 2. Amortization -- Retirement of Bonds Through Exchange of New Issue. -- The unamortized cost of issuance and the cost of retirement of old bonds are added to the cost of a new issue exchanged for the old. South Carolina Continental Telephone Co., 10 T. C. 164,…

1Opinion of the Court

Bridgeport Hydraulic Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bridgeport Hydraulic Co. v. Commissioner

Docket No. 43322

United States Tax Court

22 T.C. 215; 1954 U.S. Tax Ct. LEXIS 222;

April 30, 1954, Filed April 30, 1954, Filed

Decision will be entered under Rule 50.

1. Income Deduction -- Retirement of Bonds -- Expense or Cost of New Issue. -- The unamortized cost of issuance and the cost of retirement are deductible when bonds are unconditionally called and the debt is paid in cash even though in a separate transaction a new issue is sold at about the same time to the…

2Cases cited8 opinions

  1. Great Western Power Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  2. Commissioner of Int. Rev. v. Coastwise Transp. Corp.Court of Appeals for the First Circuit · 1934
  3. Commissioner v. Coastwise Transp. Corp.Court of Appeals for the First Circuit · 1932
  4. Helvering v. California Oregon Power Co.Court of Appeals for the D.C. Circuit · 1935
  5. Bridgeport Hydraulic Co. v. CommissionerUnited States Tax Court · 1954

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